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REACH 2018 - What Now

12 October 2018

REACH 2018 - WHAT NOW?

Whilst the 2018 REACH Registration deadline may have passed, ECHA is encouraging all registrants not too see registration as a one-off exercise, but as the start of managing substance portfolios responsibly.

A REACH Registration dossier is meant to reflect the current knowledge on how a substance can be safely used throughout the supply chain. This means that a registrant's work is not complete even once a registration number has been obtained.

Article 22 of REACH legally obliges all registrants to maintain their dossiers on an ongoing basis. It is advised that you review and update your registration regularly, even if ECHA do not request an update.

What warrants an update?

If you find out some additional information on the composition of the substance, it's properties, how it is used down the supply chain or if there is a change to the specific risk management measures needed to ensure safe use.

Any significant change in the production or import volumes and the company information must be reported.

Why are updates necessary?

ECHA and Member State authorities use the registration dossiers as a basis for further regulatory work. Information must be up to date, this ensures that authorities, and yourself, do not waste time on potential concerns that may no longer be relevant.

One of ECHAs tasks is to examine registrations to verify compliancy. A minimum of 5% of registrations from each tonnage band are checked at the point of submission. These dossiers are either selected at random or by targeting particular endpoints of concern.

ECHA study the dossiers and publish the most common shortcomings in registration dossiers. It is advised that these recommendations are checked to avoid making the same mistakes when compiling your own dossier.

If you submitted a joint registration, it is good to remember that whilst it is the responsibility of the lead registrant to complete the updates, all registrants are responsible and therefore must share the costs of correcting any incompliance or if additional information needs to be generated. In addition, ECHA have confirmed that they will start to issue compliance notices to all registrants and not just the lead registrant. Therefore, it is advised to check the dossier and raise any concerns you have with the lead registrant as soon as possible.

ReFaC can assist with dossier review and updates, contact ReFaC now for more information.

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